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ITO v. Pinki Rajesh Modi (2024) 297 Taxman 397 (SC) Editorial: Pinki Rajesh Modi v. ITO (2023) 153 taxmann.com 469/(2023) 294 Taxman 491 (Bom)(HC)

S. 151 : Reassessment-Sanction for issue of notice-After the expiry of four years-Satisfaction recorded by Joint Commissioner-The notice issued under section 148 and order is set aside by High court-Notice is issued in SLP filed by the Revenue. [S. 147, 148, 151 (1), Art. 136]

Notice under section 148 was issue beyond a period of four years after obtaining the approval Joint Commissioner instead of Principal Chief Commissioner or Chief Commissioner. On writ allowing the petition the Court held that since approval as required under section 151 had not been obtained the notice and order was quashed. Followed J M Financial and Investment Consultancy Services (P.) Ltd. v. ACIT [2023] 451 ITR 205 (Bom.) (HC). Notice is issued in SLP filed by the Revenue. (AY. 2015-16)